On January 26, 2006, Arizona state legislator David Burnell Smith became the first US lawmaker removed from office for violating a state's public campaign financing rules when the Arizona Supreme Court declined to stay a court order directing him to step down. The Citizens Clean Elections Commission voted to remove Smith in March 2005. Smith overspent during his 2004 primary race, exceeding Arizona's then $25,000 spending limit by $6,000. Arizona's 1998 Citizens Clean Elections Act made candidates who voluntarily participate collect a set number of $5 contributions from voters to qualify for public funding, and in return, candidates must follow the spending limits set by the Citizens Clean Elections Commission. Maine, New Jersey, New Mexico and North Carolina have similar campaign finance systems.

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